Pay Transparency - a Trend Becoming an Obligation
The principle of “equal pay for equal work or work of equal value” is increasingly being incorporated into the Polish regulatory framework. In practice, this means that employers will be required to maintain greater transparency in their remuneration policies, as well as to report on pay disparities between women and men.
In particular:
- From 1 January 2026, a broad amendment to the Labour Code will enter into force, which will include periods of self-employment or work under civil law contracts, among others, in the calculation of employment tenure.
- Employers with more than 250 employees will be subject to the obligation to report the pay gap (remuneration for equal work) – a result of the transposition of the EU Directive (Directive 2023/970/EU) on pay transparency.
- There are increasingly frequent proposals to include salary ranges in job advertisements or, at the very least, to present the remuneration policy in a clear and equitable manner.
Pay transparency helps prevent inequalities and strengthens a culture of trust within the organization. For employers, this entails the need to adjust remuneration policies, prepare reports, and, if necessary, amend compensation regulations.
Why this matters?
Verification of Contracts and Contractual Cooperation – a Warning for Entrepreneurs
The issue of converting B2B contracts into employment contracts under the decision of the Polish Labour Inspectorate (Państwowa Inspekcja Pracy, PiP) has been temporarily postponed. But does this mean that authorities lack tools to act in the case of irregular contracts? No. In our practice, we have encountered attempts to reclassify contracts for specific work (umowa o dzieło) into contracts of mandate (umowa zlecenia).
Why this deserves attention – KR Group Case Study:
An entrepreneur in the service sector had collaborated for years with contractors under contracts for specific work. This model was cost-effective for the company and, seemingly, safe.
- The contracts were repetitive, based on a single template, and covered the performance of specific tasks within projects executed for the company’s clients.
- The Social Insurance Institution (ZUS) challenged the nature of these contracts, asserting that contract of mandate provisions should apply.
- The decisive factor was not the contract’s title, but its content and the manner in which the cooperation was carried out.
- This created the risk of having to pay retroactive ZUS contributions for several years, with interest, as well as liability as a contribution payer, the entrepreneur’s potential financial exposure exceeded PLN 1,000,000, which could jeopardize business liquidity.
Can this be prevented? – Yes. At KR Group, we conduct a comprehensive audit of concluded contracts and the cooperation model with contractors. Based on this audit, we perform proper classification of contracts, distinguishing situations where a contract for specific work can be safely applied from those requiring a contract of mandate or another form of cooperation.
The result is streamlined relations with contractors and a significant reduction of the risk of contracts being challenged by ZUS in the future.
Should your organization currently uses contracts for specific work or plans to enter into such agreements, it is advisable to subject them to a legal audit. A properly drafted contract provides real protection against challenges by ZUS and the resulting costly financial consequences.
Why this matters?
Other Key Legal Changes in 2026 and Their Impact on Business (Civil Contracts, Commercial Law, Labour Law)
In addition to the two areas mentioned above, other changes are also on the horizon that companies should be prepared for:
- From 1 January 2026, periods of performing civil law contracts, running a business, or working abroad will also be included in the calculation of employment tenure. This will affect, among other things, annual leave entitlement, seniority bonuses, severance payments, etc.
- In the area of labour law, adjustments will be required to remuneration policies, recruitment rules, and HR processes (such as salary ranges and gender-neutral job postings) in connection with the EU directive on the application of the principle of equality.
- In the context of civil contracts and B2B cooperation, a critical issue is whether a given contract may, in practice, disguise an employment relationship. These changes mean that entrepreneurs engaging in such agreements should consider reviewing them.
- In commercial and corporate law, changes are also expected – although less definitive – and it is advisable to monitor draft legislation concerning corporate liability, the Commercial Companies Code, and required documentation. These developments may affect the terms of contractual and cooperative relationships.
What to Do – A “Checklist” for Companies:
- Audit of Remuneration Policies
Does your organization have a transparent pay policy? Are salaries appropriately justified? Are salary ranges used in job postings? Are you preparing to report the pay gap?
- Review of Cooperation Models – B2B / Civil Law Contracts
Analyze whether the form of cooperation reflects the actual conditions (e.g., absence of subordination, independence, working for multiple entities) and whether it can be demonstrated, in case of inspection, that the relationship does not constitute employment. Prepare procedures or “what-if” scenarios for potential decisions by the Labour Inspectorate (PIP).
- Update HR Documentation and Streamline Procedures
Take into account the new 2026 regulations, including the calculation of employment tenure, documenting periods of cooperation, self-employment, and work abroad. Prepare internal procedures that enable smooth implementation of these changes.
- Monitor Legal Changes and Train Teams
Inform your organization proactively about upcoming changes and prepare internal training sessions.
- Cooperation with a Legal Advisor / External Auditor
Considering the scale of the changes and risk of sanctions, consultations with KR Group experts may prove crucial.
Deregulation Act – Real Simplifications for Entrepreneurs
On 13 July 2025, the main provisions of the so-called Deregulation Act entered into force. The aim of this legislation is to improve the quality of economic lawmaking and reduce administrative burdens on entrepreneurs. The amendment introduces, among other things: The possibility of entering into leasing agreements in documentary form; An expanded definition of a craftsman, allowing for new organizational and legal forms of conducting business; Simplified rules for representing entrepreneurs before public administration authorities, through the obligation to verify powers of attorney independently in the CEIDG and KRS registers.
These changes have significant practical implications, as they reduce formalism in business operations, shorten the duration of administrative procedures, and lower the risk of formal errors. As a result, entrepreneurs gain greater flexibility in running their business and enjoy more predictable and efficient interactions with public administration authorities.
Why this matters?
50% Deduction of Revenue-Generating Costs
Under an employment contract, the standard flat-rate deduction of revenue-generating costs applies – PLN 250 or PLN 300 – but this is not the only option. In companies from the creative and IT sectors, we have introduced a much more tax-advantageous solution allowing employees to deduct up to 50% of revenue-generating costs, providing a real financial benefit to the employee. This solution can be implemented in many industries where the work has a creative character.
However, implementing such a solution must be preceded by a legal analysis. Our legal department can design and implement a comprehensive solution for your organization, including: analysis of job positions, preparation of a creative activity regulation, modification of employment contracts, and implementation of a system for recording creative work.
Applying the 50% deduction of revenue-generating costs can bring tangible benefits, provided it is implemented correctly. We invite you to a consultation that will allow you to safely organize or design the entire deduction model.
Why this matters?
Prohibited AI Practices – Emerging Regulatory Risks for Business
Since February 2025, the provisions of the AI Act have been in force, prohibiting the use of artificial intelligence systems that pose so-called unacceptable risks to fundamental rights. These prohibitions specifically cover: the use of AI for subliminal manipulation; exploiting vulnerabilities of certain social groups, including children, the elderly, or individuals in difficult socio-economic situations; mass collection of facial images from the Internet or surveillance systems; analyzing the emotions of employees or job candidates based on biometric data.
Violating the prohibitions set out in the AI Act carries the risk of severe administrative penalties, reaching up to €35 million or 7% of a company’s total annual global turnover. Regulatory liability applies not only to technology providers but also to entities using AI systems in operational activities, particularly in HR, recruitment, marketing, and customer service.
Why this matters?
KR Group’s Perspective
The upcoming changes are not merely formal in nature. We encourage treating them as an opportunity to strengthen internal processes, build competitive advantage through good HR practices, and ensure compliance, rather than merely as a legal obligation to be fulfilled. If needed, we remain at your disposal and are happy to assist you in the analysis and implementation of the necessary measures.
Disclaimer: The above information is provided for general informational purposes only and does not constitute legal advice. Each case requires an individual assessment; before making any decisions based on this information, it is recommended to consult a qualified lawyer, competent authority, or relevant institution.
